Finding Text
2023-002: Special Tests and Provisions - NSLDS Program - Level Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P221544, P268K231544 Award Period: July 1, 2022 - June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per the NSLDS Enrollment Reporting Guide, Published Program Length should be reported to NSLDS based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows: If the school has published, in it's catalog, on it's website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school published. If the school has not published a program length and the program is an associate or bachelor's degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. For all other programs for which the school has not published a program length, the program length is based on the school's determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Questioned costs: None Context: The condition occurred for 38 out of the 40 students tested Cause: The program length reported to NSLDS for associate degree programs is maintained in the College ERP system based on program length in months and was not converted to years as recommended in the NSLDS enrollment reporting guide. Effect: The NSLDS system calculated the program length at 2.678 years. Repeat Finding: No Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Views of responsible officials: There is no disagreement with the audit finding.